Here I present my research findings on moral legitimacy in practice to WaterAid UK staff. This presentation was delivered on July 25, 2018.
Here I present my research findings on moral legitimacy in practice to WaterAid UK staff. This presentation was delivered on July 25, 2018.
To fellow SOAS post-graduate researchers – farewell and best of luck from your 2017 – 2018 campus representative.
On Monday, Marc and Jodie Emery, Canada’s “Prince and Princess of Pot”, plead guilty to two charges; possession of cannabis for the purposes of trafficking, and possession of proceeds from crime. While they did not receive any jail time, they will both be on probation for two years, and have been hit with a combined fine of $390,000. Both Marc and Jodie have dedicated their lives to advocating for the reversal of cannabis prohibition. Despite seeing their life’s work finally coming to light, criminal records will prohibit them from entering the soon to be legal cannabis market in Canada.
Like Marc and Jodie, many experts in Canadian cannabis are currently unlicensed growers and distributors. Technically, these small to medium sized businesses have been, and are, operating illegally under Federal law. However, provincial and municipal governments have historically had little incentive to strictly police such businesses. With the legislation of cannabis just around the corner and new found economic incentives attached to policing these business, we will likely see a hard crack down on unlicensed growers and distributors. Eliminating the competition is just one example of how our provincial governments are attempting to secure a strong monopoly over a promising emerging global market.
Lets take Ontario as an example. Following the financial success of their monopolisation of the alcohol market through the Liquor Control Board of Ontario (LCBO), the government recently passed the Cannabis Act, creating a provincial agency for the retail of cannabis online and through store fronts. The Act also gives policing authorities the mandate to swiftly eliminate any business competition. People and businesses that operate in parallel to government run retailers could be hit with hefty fines and/or jail time. Most disturbingly, the Act infringes on civil liberties by allowing police units to close down the competition before they are convicted of any charge…I guess the presumption of innocence under Article 11 of the Declaration of Human Rights does not apply when the government is operating within a conflict of interest eh?
(1) Everyone charged with a penal offence has the right to be presumed innocent until proved guilty according to law in a public trial at which he has had all the guarantees necessary for his defence.
(2) No one shall be held guilty of any penal offence on account of any act or omission which did not constitute a penal offence, under national or international law, at the time when it was committed. Nor shall a heavier penalty be imposed than the one that was applicable at the time the penal offence was committed.
After the passing of Ontario’s Cannabis Act, Theo Moudakis captured the sentiment across the province perfectly in his Marijuana Monopoly cartoon in the December 14th issue of The Star. If other provincial governments follow Ontario’s questionably corrupt example, the experts of Canadian cannabis could soon be out of business and hit with criminal charges that would inhibit their re-entry to the market.
You might be asking why these currently illegal entities don’t just start operating legally. Well, the reason there are so many unlicensed businesses currently in operation across Canada is largely because the federal application process for becoming licensed is very stringent and time intensive. Like in most markets, large scale business with a significant amount of capital tend to face little challenges in becoming regulatory compliant, while the little guys face numerous hurdles. This has certainly been the case with the medical cannabis industry in Canada, and will compound both government and big business monopolisation of the recreational market.
Already licensed producers have a massive head start entering the recreational market, and big business monopolisation of the market is good for government monopolisation of the market. By working with a small number of large scale producers, governments can more easily control the market. We have seen this happen across industries time and time again (banking would be the most obvious example).
So far, within the legalisation of marijuana debate across Canada, I have seen little space given to the consumer perspective. I don’t know about you but I’d rather buy my weed from small business owners passionate about what they do – like those associated with Cannabis Growers in Canada – than from people like Toronto’s former police chief Julian Fantino, who once ignorantly compared legalizing marijuana to legalizing murder. As a consumer, I would also like to ensure high product quality, and would enjoy the freedom of product choice created by a diversified market. The monopolisation of the legal cannabis market that we are already seeing sweep across Canada will offer little benefits to the consumer.
Consumer perspective aside, this debate is about more than just cannabis. I am not personally starting to engage in this debate because I want to smoke good quality weed when I am in Canada (mom I am talking to you as you scowl reading this). I am engaging in this debate because it is ultimately about the society that I want to live in. This is about preserving space for small businesses and generating wealth within communities. This is about environmental sustainability and environmentally responsible agriculture. This is about holding governments accountable and demanding a system that serves the interest of people first. This is about protecting democracy and civil liberties. This is about doing harm reduction and primary prevention right. This is about shining light on truth by de-stigmatizing both people that have been criminalised for cannabis related offences, and a plant that has been scientifically proven to be relatively harmless and helpful. For these reasons and more, I intend to add my voice to this debate.
Activists like Marc and Jodie have admirably sacrificed much to move the legalisation debate to where it is today (if you are in a position to give back to them consider helping them cover the costs of their hefty fines here). While our governments and big business are actively trying to push them out of what they helped create, they will not be silenced! This will awaken a new generation of activists. A generation of activists that will find strength and success in shared values and ideology.
~Robyn Waite (December 20, 2017)
I had a blast speaking at a rally on campus last week in solidarity with SOAS support staff. Although it has been more work than expected, I am learning heaps from being in the Post Graduate Research Officer role and President of the Research Students’ Association on campus. While at times it can be frustrating and discouraging to see policies developed in such a haphazard way, diplomacy and dialogue are critical to moving forward constructively. Here’s to not only influencing specific policies on campus, but to facilitating the development of community norms that will benefit the institution as a whole.
In an attempt to being as accessible as possible, here is the speech in written form.
My name is Robyn Waite and I am the Post Graduate Research Officer and President of the Research Students’ Association (also known as the RSA).
To be honest this has been my first experience really engaging with campus politics. When I started in this role I had no idea I would be fighting so hard to put out fires and to have our voices heard. My default assumption was that the Senior Management would approach decision making sensibly – consulting stakeholders on decisions that affect them, ensuring transparency, and coming to thoughtful decisions having done essential research. I’ve been surprised and deeply disappointed that this not the case. Let me give you one recent example from the research student perspective.
Last week, we received an email from the School introducing a new attendance policy for Tier 4 research students. This policy would have had students’ checkin with Doctoral School support staff, in person, every three weeks, on a predefined date. It would have also required students to seek approval from the Doctoral School for any and all travel outside of the UK. While universities have to be able to demonstrate they comply with Home Office regulations, universities have much autonomy around how they go about doing this. A review of practices across other UK academic institutions demonstrates the policy developed at SOAS to be particularly inflexible and burdensome for students and support staff alike. For example, most other universities logically include supervisory meetings as key points for recording research student attendance. Not surprisingly, this particularly draconian policy released by SOAS caused much distress amongst the student body. The day after this policy was announced I myself was off to Amsterdam for a lovely long weekend with my husband. I felt very uncomfortable feeling as though I was already in breach of this new policy, and my stomach turned at the thought of my privacy and freedom of movement being infringed upon.
While strong opposition to the introduction of this new draconian policy at SOAS has resulted in its suspensions until consultation with the RSA takes place, this experience has raised serious concerns around how critical decisions are made on campus. It appears this policy was developed not only without consultation, but with little consideration of the current student and support staff experience, and without attempt to conform to sector norms or the values of SOAS.
The Doctoral School has been inadequately resourced and supported by SOAS Senior Management for far too long. Only recently, and thanks in large part to the lobbying efforts of existing Doctoral School staff, 4 new members of staff were hired. We were under the impression that these new members of staff were hired to meet existing critical capacity needs. As such, it was unfortunate to see a policy introduced which would result in staff having to unnecessarily attend to an administratively burdensome new attendance policy rather than support students. As a research student body, we are deeply concerned about how such a policy would further stretch Doctoral School staff and deteriorate the research student and staff experience. In order to understand the current context, Senior Management must consult both the implementers of new policy, and stakeholders affected by new policy.
Sadly, the Doctoral School not being adequately resourced and supported by Senior Management has resulted in division between support staff and the research student body. Front line Doctoral School staff tend to bear the brunt of student and faculty frustration. This is not fair nor justifiable. We must come together in solidarity with support staff across SOAS. We are the life blood of SOAS, and collectively we have the power to create a community whereby transparency, consultation, respect, and informed decision making become the norm.
~ Robyn Waite (November 27, 2017)
I am happy to share that Matt and I are officially Mr. & Mrs – although I will be keeping my last name for all the reasons laid out here 🙂
We had a beautiful ceremony and evening celebrating with our nearest and dearest along the Ottawa River on July 15th. Family and friends travelled far and near (including from New Zealand, Australia, London, Russia, the US, and West Coast of Canada) to be with us on our special day. In planning our wedding we took care to give our guests a taste of who we are as a couple, and we choose not to conform to typical wedding customs. Let me walk you through some of the highlights.
Walking down the aisle together
In order to symbolise that we were entering into this marriage as equals, Matt and I elected to walk down the aisle together. As a woman, this also empowered me to push back against the patriarchal tradition of the bride being given away. It was super cute. Matt came to get me from inside the boathouse (he even knocked on the door….it melted my heart instantly), and we walked down the aisle hand in hand. I now know why most brides go with arm in arm though, my beautiful bouquet was waved all over the place.
Sharing vows that will make you feel born again
Matt and I wrote our own vows for the ceremony. Have a read of both below and you will catch a glimpse of how we feel about one another and our existence. Interestingly, we didn’t share our vows with one another ahead of the wedding, yet they ended up being so similar…. almost as if we were saying the same thing, just in the opposite way. But then again, if how we feel about each other and this existence is true, I wouldn’t expect otherwise. Reflecting on this the week after the wedding literally made me break into tears of joy multiple times. It was as if I was born again. The content of our vows and the process of making them to one another gave me complete affirmation of our evolving philosophical understanding.
Matt, everything in this infinity literally has an exact match. You are mine – my exact opposite – the ying to my yang, the acid to my alkaline, the disciple to my prophet. Together we form a binary system. We are each other’s one true love. Given this sole truth, I vow to complete you forever.
If there wasn’t you, there would be nobody. With you, I can truly be myself, and having experienced this pure joy, I promise to always have absolute faith in us.
As your best friend and confidant I vow to always try to see what you see, to support and encourage you in all your endeavours, and to question you often in order to push you to your ever evolving potential.
I’ll be with you for eternity – In sickness and in health, in successes and in failures, in harmony and in chaos. Through it all and from this day forward, I promise to keep learning what it means to be in love with you.
Robyn, Thank you for choosing me to share your wedding day with, and for gifting me our future together.
You are my muse. You bring me life, love, song, contradiction and completeness – and I am so honoured to be partners in this journey.
I promise to empower you and protect you; to challenge you, learn from you, and teach you; to let you grow as an individual; and grow with you. I promise you a bond that will not break, that will grow stronger and deeper, and that you can rely on, always.
In chaos, you are my constant – and I promise to be your anchor to a reality filled with love, happiness, excitement and adventure. This is why I’m marrying you. We connect like no other.
A bubbly ceremony
For celebrating throughout the ceremony, everyone was greeted with a glass of prosecco upon arrival. Rather than have everyone sit during the ceremony, people crowded around and stood to watch (expect of course those that needed to sit). We also didn’t have a traditional wedding party as part of the ceremony. We wanted to keep the focus on us and really couldn’t see the purpose of having more than our witnesses (my beautiful sister and Matt’s bro) up there with us. We kept the ceremony short and sweet and included a cultural blessing from Matt’s mom to honour the diverse cultures our union has, and will continue to bring together.
Food and drink that tell our story
The food and drink we had on offer was carefully thought out in order to tell our story. We elected not to have a sit down dinner and instead turned our wedding into our favourite Street Feast in London. This way our guests were free to socialise the entire evening. Food was passed throughout the course of the entire event, ranging from canapés to street feast bites, a taco stand, dessert bar, and poutinerie. Matt and I met in India so we made sure to have a curry on offer; we currently live in London England so included fish and chips; Matt is from New Zealand (NZ) so we naturally served up NZ lamb chops; and all Canadians will advise poutine after a night out of drinking so that was definitely on offer as a late night snack. For drink, we went with wines from vineyards we visited while in NZ last year, and his and her local Ontario craft beer (we of course also had bubbly and a selection of cocktails on offer).
Entertainment that tells our story
For music, we had the DJ mix our London Town Spotify playlist, which we have been cultivating for three years now. We wanted everything about the day to reflect us and our journey together, so when the DJ went down an MJ or Pink path a few times in an attempt to get people dancing, we quickly reigned that in.
Our first dance was epic. We danced and sang along like know one was watching to “Love on the Brain” by Rihanna. If you know the song you might think “but really…isn’t that a little raunchy and less than PG”?? Yup…but we didn’t care. As a song it speaks to us, which we thought was the point of a first dance. A lot of people thought we might have choreographed our dance – we didn’t – we just dance like that together at home all the time so it comes naturally now.
For speeches, we had two of our great (and dramatic) friends MC, and people came up to give what we called “quick fire” speeches. We didn’t want anyone going on for too long and made sure guests knew that they didn’t have to stop what they were doing in order to listen. The venue’s stairs ended up offering a great platform for speeches and it was cool how guests casually sat on the steps to watch and listen. Just in case anyone got bored during the day we also had life size Jenga and bean bag toss for garden games.
It’s the people that count
Matt and I had an amazing day. Although a lot of thought went into making sure our day was a reflection of us, it was all done with the intention of sharing a piece of ourselves with our guests. We weren’t in the least bit stressed leading up to the big day (seriously I got “you are the most chilled bride ever” on more than one occasion). Ultimately, we knew that all that really mattered was the people that would be there to celebrate with us. We wanted an intimate wedding so we only had about 80 of our nearest and dearest in attendance. These were the people that really made our day. We love you all dearly and are so grateful to have you in our lives!
Photographer: Agatha Rowland
Catering: Thyme & Again
Makeup: Done by Amber from Liana LaCroix Beauty
Florist: Harmony Florals
Officiant: Paul Racine, Doulous Ministries (and my past football coach)
Venue: Ottawa Rowing Club
~ Robyn Waite (September 8, 2017)
Like many, I am utterly appalled by the Grenfell Tower fire that claimed the lives of so many last week. The life lost is deeply saddening, but what makes this so infuriating is that the tragedy was entirely preventable. Fire did not kill these people, neglect and exploitation of their vulnerability did.
Since the fire, the nation has been screaming for justice. In response, Theresa May has committed to a full public inquiry into the matter, although it is worth noting that many are demanding an inquest instead, as such an approach would be independent from the state (take a look at this article to get a grasp of the significant differences between an inquiry vs. inquest). While I of course want justice for the victims of Grenfell Tower, it doesn’t take a formal investigation nor hearing to realise that the events that led to this tragedy being possible in the first place, were criminal.
The cladding used to make the tower less of an eye sore amongst an otherwise insanely wealthy borough was illegal for use in the UK. Despite policy and national recommendations, sprinklers were not installed throughout the building, fire alarms were non-functional, and emergency vehicle access routes were restricted. The Grenfell Action Group had been trying to have their voices heard over these very issues for years. They specifically flagged their concerns over fire safety to their local Kensington and Chelsea Council, councillors, and MP, as well as raised complaints against their Tenant Management Organisation. Quickly realising their lack of power, they chronicled their entire experience through blogging – you can read it for yourself here. The evidence of neglect this vulnerable population faced is substantial and infuriating to bare witness to, especially considering most residents were living in social housing and lacked the ability to move despite fear over their safety.
It is clear to see that the very structures of government put in place to represent constituents, are seriously flawed. And sadly, this utter disregard for communities and lack of adherence to protective planning policy is rife across the country and all levels of government. Given this stark reality, to me, the only real potential path to justice is to mobilise as a city in response to the Grenfell Tower fire. We must highlight our individual stories in order to reveal the true systemic nature of the problem. Only then will we have the power to demand reform of the planning process and reclaim our voices in community consultations. Because I believe that this is the only path to justice, I feel that it is my duty to once again tell my community story engaging with local planning – this time explicitly calling attention to similar experiences of neglect and exploitation of vulnerable populations.
I have chronicled the Woolwich Royal Arsenal community experience engaging with an atrocious planning application submitted by Berkeley Homes to Greenwich Council for over a year now (see my blogs from November 2016, February 2017, March 2017 & May 2017). The now approved plan includes building an 11 storey tower block on top of an existing listed heritage building within a conservation area. The construction of this building will negatively impact hundreds of residents, in many cases significantly compromising their quality of life.
The existing buildings that will be most impacted are Bentham House, 7 floors high, and East Carriage House (ECH), 6 floors high. Both are predominantly social housing, and represent the two buildings that will be on either side of the forthcoming tower block. Bentham House is exclusively for people aged 55 or older, meaning this is a particularly vulnerable population. It is worth noting that some of the elderly residents of Bentham House are in poor health, and will be significantly impacted by dust and air pollution caused by construction right outside of their homes. Both buildings, and particularly ECH, will be significantly affected in terms of lack of access to daylight/sunlight and privacy. The proposed tower block will be less than 15m away from ECH, and less than 26m away from Bentham House.
Over the course of the past year, I have repeatedly pointed out that the community felt excluded throughout this planning process. Let me explain why.
First and foremost, the entire process of community consultation is inherently inaccessible. When consulting the community, the council sends residents notification of the application via the post, and requests a response within a rather short turn around period of 21 days. Below is an image of the front page of the notice of this planning application from Greenwich Council. I mean, is that even legible?
Once the open consultation period with the community closes, all residents that make a submission, either in support or objection to the application, are to be invited by the council to attend the related planning board meeting where the application will be reviewed.
In our case, the council had to do two rounds of consultation ahead of the application being presented to the planning board, as Berkeley Homes was subsequently required to make their viability assessment publicly available. The community consultation was set to formally close on November 16th, yet invitations to the planning board meeting scheduled for November 22nd, were sent to residents via email on November 15th. A planning board meeting agenda pack was provided with the invitation, within which, the council planning officers recommended the application be granted full planning permission. This means that planning officers made a decision to recommend planning permission before the community consultation came to a close. This calls into question whether or not the community voice was considered in their recommendation. Sending invitations to the planning board meeting on November 15th, also means that some members of the community intending to make a submission to the council before the close of the consultation period on November 16th, would not have received an invitation to the meeting.
More shockingly, within the planning board meeting agenda pack put together by the planning officers, a critical voice for residents living within ECH was omitted. Southern Housing, the housing association that manages affordable housing within the building, submitted the below comment. Interestingly, the comment is tagged as “Neutral”. However, reading the comment they are clearly concerned about the “level of harm” the proposed tower block would have on their tenants (note ADF = average daylight factor).
At the November 22nd planning board meeting, the application wasn’t granted planning permission due to issues concerning safety and vehicle traffic flow in the area. As such, the application had to be amended, and the council had to do another round of community consultation (which I note they did over the December holiday season while many people were away).
At this point, many residents were confused as to whether or not they needed to re-submit their original letters of objection for consideration at the next relevant planning board meeting. As such, one resident sought clarification from a planning officer on the case. The officer told this resident that no, they did not have to re-submit their original letter for it to be considered. While this was technically true, it became apparent at the planning board meeting held on January 16th, that it would have been in the community’s interest to resubmit original letters of objection. Planning officers presented the total number of notices of open consultation sent to residents over the three rounds of consultation + the total number of letters of objection received over the same period, thereby diluting the perceived level of community objection to the application.
Ahead of the January 16th planning board meeting where the application ended up being approved, the council also did not release meeting minutes from the November 22nd board meeting until the day of the meeting (Jan. 16). Many members of the community, myself included, made inquiries into gaining access to these minutes, as we strongly felt they were required in order for all parties to prepare for the meeting and for the planning board to make an informed decision on the application. Finally, after countless efforts to raise concerns over these minutes not being shared, I received a response from someone at Greenwich Council that at least understood our frustrations (see partial response below).
Lastly, it should be noted that elderly residents of Bentham House whom did not have access to email faced further exclusions in the consultation process. While I received invitations to planning board meetings via email one week in advance of the date, residents corresponding with the council without an email address received invitations via post only two days ahead of scheduled meetings.
Berkeley Homes submitted their own commissioned report on daylight/sunlight to the council. However, recognising the report to be biased and flawed, the community had three separate daylight/sunlight experts review its contents. Their respective responses – parts of which are quoted below – highlight concern over the methodological approaches used within the report, as well as demonstrate the scale of the impact of the tower block on existing residents. A few key flaws to highlight include the report using a larger sample size of flats than relevant to the analysis in order to downplay the proportion of flats that will be below national daylight/sunlight standards, it inflating daylight values by allowing for internal reflectance and lighting, and it applying a method called “mirror massing” which assumes the proposed tower matches the height and proportions of existing buildings in the area (not the case here).
“The mirror-massing principle assumes that the Heritage Asset could be entirely removed. If it is retained and a mirror massing development placed solely on the Building 10 building area, this would result in a very different set of daylight results [than what is present in the report]. The use of mirror image analysis and analysis removing balconies is permitted in the BRE Guidelines. It is unusual, however, to use both methods [as done within the report]. The BRE Guidelines state that alternative target values may be set and so it is likely planning officers have been persuaded on this matter.”
“The Daylight Distribution results show reductions of up to 50% to Bentham House and of up to 92% in ECH, leaving many rooms unable to see the sky from over half their area. Such reductions will clearly leave these rooms significantly gloomier than previously, and arguably not appropriate for habitation… Internally to the propo[sed tower], the report states 60% of habitable rooms meet the BRE Guidelines for their room use. Usually, planning officers look for at least 80% compliance across a scheme this size.”
Given these responses, it was concerning to the community that the planning officers with the Greenwich Council on this case failed to critically review commissioned reports submitted by Berkeley Homes. Perhaps even more concerning, despite this being the most contested issue raised in letters of objection from residents, planning officers failed to present the impact of the proposed tower block on existing residents access to daylight/sunlight at the November 22nd planning board meeting (you can access the ppt. slides they presented here).
It was not until the second planning board meeting on January 16th that planning officers presented information showing impact on daylight/sunlight. The below images presented that evening illustrate the gravity of the impact, with almost all units in ECH directly facing the tower block set to loose access to daylight/sunlight below national standards (blue represents units not compliant with BRE standards). It should be noted that because these are single aspect flats (meaning they only have windows / access to natural light from one side of the flat) higher standards should apply. London Housing Design Standard 5.2.1 states “where single aspect dwellings are proposed, the designer should demonstrate how good levels of ventilation, daylight and privacy will be provided to each habitable room and the kitchen.”
With introduction of tower:
Planning officers were similarly uncritical of the applicant in multiple other instances and consistently presented misleading illustrations and misinformation to the planning board. For example, the image below presented to the board was riddled with errors. Bentham House has 7 floors, not 8; the tower block will have 11 floors, not 10; in reality, the heights between Bentham House and the tower will be by no means comparable; and the distance between ECH and the tower is actually 14.4m and for those on the 1st floor of ECH a mere 11.3m.
Royal Borough of Greenwich’s Policy DH(b) Protection of Amenity for Adjacent Occupiers states that “when determining applications for new developments, extensions or renovations of buildings, the Royal Borough will only permit an application where it can be demonstrated that the proposed development does not cause an unacceptable loss of amenity to adjacent occupiers by reducing the amount of daylight, sunlight or privacy they enjoy or result in an unneighbourly sense of enclosure.” It is interesting that the new tower block that will include zero affordable homes will not have flats facing towards ECH. Clearly that would be an unacceptable loss of amenity and privacy for its residents, yet they seem to be okay with breaking this policy in respect to ECH residents. Curious…
You might be asking yourself how the heck Greenwich Council, like Kensington and Chelsea Council, get away with this type of conduct. To be honest, the reasons are deeply complex and worth an entirely separate blog. That being said, part of the answer lies with the Greater London Authority (GLA). After a planning application is approved by a local council, it goes up to the Mayor of London’s office. Essentially, they are supposed to act as gate keepers and protectors of the London Plan.
As a community, we sat down with the GLA planning team and pointed out the multiple breaches of policy associated with this planning application. We also pointed to multiple examples of where Berkeley Homes’ various reports were inaccurate, misleading, and methodological invalid, and questioned why Greenwich Council planning officers were not being critical of the applicant. Despite telling us that our concerns were legitimate and that they would need to take a least six months to thoroughly review the case, planning officers with the GLA quickly went on to recommend planning permission inline with Greenwich Council planning officers – literally no questions asked (you can read their report for yourself here – note they do not provide justifications for why they take the view of Greenwich planning officers over the community in multiple instances).
This whole experience has been extremely infuriating and demoralising. In addition to all I have told you here, just before the GLA released their report, on March 15th I stumbled across all key stakeholders with significant influence over the outcome of this planning application catching up for a pint at our local (this included the lead Greenwich Council planning officer, lead GLA planning officer, and Berkeley Homes Regional Chairman). As usual, I chronicled the experience, and as what has come to be expected, our attempts at having our concerns heard over lack of impartiality of all parties involved were silenced (see Didn’t your mother ever tell you not to eat where you shit? and All roads lead to the swamp).
Clearly this is a systemic problem that requires substantial reform to how planning applications are developed, reviewed, and approved in London. I for one refuse to sit back while the norm includes communities having little voice, planning officers failing to be adequately critical of applicants, and arguable unprofessional relationships between key stakeholders accepted. On its own, this account is unlikely to result in any change. However, there always has been, and always will be, power in collective story telling. The victims of Grenfell Tower need us to share our accounts of similar neglect and exploitation with planning processes and authorities. Together we can collate a flurry of case studies and unite in our cause. Clearly working within the system to fight individual planning battles only as and when they directly impact us, isn’t working. It’s time to fight the system!
*Robyn Waite (June 23, 2017)
NOTE: If you have a story to tell please notify me when you share it publicly. This way we can compile all our accounts and hopefully present them to an interested journalist or use them in future advocacy efforts. If you have a story to share but want to do so anonymously, or do not have a platform for publishing, don’t hesitate to get in touch with me as I would be happy to post your account as a guest blog. You can find my various contact details here.
You might remember my most recent blog concerning a highly controversial local planning application – Didn’t your mother ever tell you not to eat where you shit. Following legitimate community upset about what would be comparable to judge, jury and prosecutor all socialising mid trial (and being caught red handed by the little guy on the defense), we took multiple actions to have our concerns heard. Despite our efforts, we were stoned walled at every turn. Sadly, this lack of respect for the community and refusal to take us seriously is nothing new, emerging as a theme across all blogs I have written in order to chronicle our experience (see blogs from this past November, February and March).
Immediately after writing my juicy blog that raised questions of the impartiality of the planning officers on this case, naturally I posted it on Twitter and tagged my local Labour MP – Matthew Pennycook. His initial response was positive in that he too perceived the socialising of all parties involved in this controversial planning application under review as “concerning”. In addition to this, in an email to residents he said “in my view, it is vital that planning officers, whether they work for the Royal Borough of Greenwich or the Greater London Authority, not only carry out their duties in a transparent, fair and impartial manner but are seen to do so”. #Preach!
After “taking it up with the Council and Mayor’s office” as per his Tweet, he suddenly went silent and refused to engage publicly on the topic further (you can see my attempts at getting him to respond in this Twitter thread). This sudden change of heart was initially quite curious to me, but upon reflection I have come to the conclusion that Pennycook must just be a ‘fall in line’ kinda guy. Remember when Leader of the Labour Party Jeremy Corbyn put pressure on his MPs to fall in line with the Tory government in the vote to trigger article 50? Well Pennycook did just that despite a clear majority of his constituents voting remain. It seems to me that he has forgotten that politicians who yield more power than him do not hold power over his seat…the people do.
Considering Pennycook wouldn’t comment further publicly, you can read his email correspondence with residents for yourself. Within, he states:
Having been made aware of the fact that Mr Wilson attended Mr Parker’s retirement party at the Taproom on Wednesday 15 March, I immediately sought reassurance on behalf of residents from James Murray, the Deputy Mayor for Housing and Residential Development, about the process by which the GLA will determine the planning application in question. Mr Murray has confirmed that the GLA have not yet made a final decision with regard to the proposals for Buildings 10, 11 and Royal Carriage Square. It is the Mayor of London, not GLA planning officers, that will make the final decision on the planning application. The document dated 20 March that was passed to you by the office of Len Duvall AM is not notification of planning approval; it is the GLA planning officers’ recommendation that will go to the Mayor for consideration on that date. Having considered the matter carefully, the Mayor may ultimately be content for the Council to determine the application or he may not but either way I know that he will make his decision transparently, fairly and impartially.
Not overly reassuring is it? We got similarly daft responses back to our complaints raised from both the Local Greenwich Council and Greater London Authority (so you can read our complaints submitted as well as the responses for yourselves, I have linked the preceding text to both correspondences respectively). To sum it up, all avenues taken by the community to escalate concerns over the impartiality of all parties involved were dismissed with no further investigation and mere verbal reassurances that everyone involved in the decision to grant this controversial planning application approval were, without question, impartial.
I’m sorry ya’ll, but I don’t think the community will be taking your word for it anytime soon. How can you expect the Mayor of London to make his decision transparently, fairly and impartially, if his decision is being informed by recommendations from planning officers that may lack such characteristics? And if you see it as normal for literally ALL key stakeholders with significant influence over the outcome of planning applications to have close personal relationships with one another, then perhaps we should really be questioning a more systemic problem.
I’d like to point out here that the report recommending the planning application be approved, was sent to the Mayor by Colin Wilson’s team on March 20th, and the Mayor made his decision to approve the plan on the basis of that report, on March 20th. I’d also like to point out here that as per Matthew Pennycook’s correspondences with concerned residents, James Murray was made aware of these concerns on either March 17th or 18th. As you might expect, the community has questioned why a decision would be so quickly taken by the Mayor when concerns over the impartiality of the planning officers involved throughout this case were made known to his staff. Surely we aren’t a group of bat shit crazy residents merely moaning if our local MP, Nicky Gavron, and Greenwich LibDems among others all see something “concerning” here.
And yet the plot still thickens. Not only were our concerns dismissed, we were blocked from raising our concerns in a public forum. We submitted the following questions for a local council meeting, and they were rejected:
Our supportive local Councillor John Fahy responded saying, “I have been the Riverside Councillor for the last twenty seven years. I have never seen this happen on any previous occasion…I am, frankly, lost for words. Bad day for democracy.”
In addition to this, after Pennycook went silent, we gained valuable insight into why he wouldn’t support us in our campaign. Before the incident at the TapRoom, a group of Royal Arsenal Residents went to his surgery hours requesting his support in opposition to the planning application. He responded by saying planning was not his responsibility and as such, that he could not take a position. In communications with other similarly concerned residents, he expressed that he had no influence over whether or not planning applications were approved and as such, could merely observe. Indeed, it was interesting to then come across his posts on social media making clear statements in support of residents campaigning on planning matters in other areas of Greenwich.
I think the Facebook thread version of this dialogue below is the most entertaining and revealing. Firstly, Pennycook demonstrates that, contrary to what he implied to many Royal Arsenal Residents, he can take a position on planning matters. This begs the question of why he repeatedly declined to support his Royal Arsenal constituents. Secondly, he puts his foot in his mouth by suggesting the history of planning proposals in the area somehow weighs into what is acceptable in the current application…and the current application is literally appalling in terms of negative impact on vulnerable populations, the environment, and heritage of the site. He also discourages community engagement in local planning by implying that residents made their bed by opposing the 2014 application which “had much to commend it” ….say what? Needless to say he had no further comment.
Sadly, we as residents are at the end of our rope. Personally, I am broadening this fight to be about how our government conducts business. Clearly it is time to drain the swamp. Matthew Pennycook told me to have my say over his performance at the next general election. That opportunity appears to have come sooner than later, and given it would be really hard to vote for him after this experience, Greenwich and Woolwich Liberal Democratic candidate Chris Adams will likely be getting my vote.
*Note – in addition to not being able to bring myself to vote for Pennycook, Chris seems like a stand up guy. He is well educated, passionate and progressive in his political thinking. From my perspective, the LibDems manifesto also has much to commend in it, and after Corbyn’s no show at last nights ITV debate I have serious questions about the Party’s principles and respect for democracy. I realise that the stakes are high this general election but considering this is a safe Labour seat a little protest vote likely won’t hurt anyone.
¬ Robyn Waite (May 19, 2017)
As a health professional that specializes in water, sanitation, and hygiene (WASH), I know full well that no one can get away with their health intact if they eat where they shit. Apparently Greenwich Council planning officers missed that memo.
Yesterday was a beautiful sunny day in London. As such, I inevitably went to my local pub for a relaxing drink on the patio. While there, some people were setting up for a party. Seeing their pictures and posters, I quickly realized it was a leaving party for Andrew Parker. Andrew was the Greenwich Council planning officer in charge of the controversial planning application recently approved in my community.
As you will have gathered from my past blogs on this (see “Sticking it to the man” and “Nevertheless She Persisted”), the community has perceived the planning officers on this case to have been shockingly biased in their position of support for the application. Needless to say, many members of the community are not too impressed with Andrew Parker. This begs the question of why the heck he and his colleagues would elect to host his leaving party at the community crowd funded pub located in the very center of this controversial planning application. Let me tell you, the audacity of him having his leaving party at the Tap Room, grated my nerves.
While some of Andrew’s colleagues were setting up for his party, my friend and I got to chatting with them. I mentioned the pub we were currently at was in the center of a planning application Andrew recently worked on, so I knew who he was. During our discussion the young lad mentioned that Berkeley Homes, the developer behind the planning application, would soon be joining the party to see Andrew off. I almost laughed out loud! Oh really? Andrew has that good of a relationship with Berkeley Homes? Maybe the level of bias he demonstrated throughout the planning application process could be explained after all?
At this, I decided to stick around for the night to see what happened and to make my presence known. All parties would surely squirm and feel slightly uncomfortable by me being there – I had after all, played a prominent role in mobilizing an impressive community response to the application, was very vocal at planning board meetings, and was on London-live News / quoted in various news articles speaking out on the issue.
Andrew was one of the first people to arrive to the party. He noticed me sitting outside and quickly ducked into the bar until more of his people arrived. Sure enough, not too much later John Anderson, the Regional Chairman for Berkeley Homes rocked up. Then something I wasn’t expecting happened…Colin Wilson, the planning officer with the Greater London Authority (GLA) in charge of reviewing the council’s decision to approve the application, walked in.
A few weeks ago myself and other members of the community had a meeting with Colin and one of his colleagues at the Mayor of London’s office. At first, we were only meeting with his colleague, but about ten minutes into our discussion Colin showed up. At the time, I was pleased that such a senior member of staff was taking an interest in hearing the community perspective. However, looking back, I now think his interest in being there was to control the discussion and be able to report back to other stakeholders interested in keeping our opposition under wraps. Upon further reflection of something Colin had shared with us during the meeting, this 3-way conflict of interest now slapping me in the face makes total sense. About ten years ago, paraphrasing what Colin shared, “East and West Carriage House were his claim to fame”. He contributed to their design and approval. So…the person charged with reviewing the council’s decision to approve Berkeley Home’s application has a long standing relationship with both the local council and developer in question…how disturbingly interesting.
As I am sure you could have guessed by now, I was pretty upset last night. Keeping my cool however, I solicited help from other members of the community, and together we documented the night by compiling photographic evidence of all parties schmoozing. Sadly, the controversy doesn’t end here. While in the middle of writing this blog, we got tipped off that Colin and his team recently approved the council’s decision to allow the planning application to go forward. Alongside this distressing news we were sent the report authored by Colin and his GLA team.
Now this flags up soooo many more alarm bells. Does that mean that in addition to seeing Andrew Parker off, all parties were celebrating the approval of this planning application? Why was the community not directly informed of this development, and why is the report dated March 20th when it’s the 16th today? Also note that when we met with Colin and his colleague on February 13th, we were specifically told it would take them months (not weeks) to review all information and come to an informed position on the case. This clearly demonstrates the lack of respect given to our legitimate concerns as a community and begs the question of whether or not the GLA conducted a thorough review of the case at all. Upon reading the report, it would appear not (you can read the report and make up your own mind here). Throughout the report, they fail to justify why they take the positions they do, and simply state “GLA officers share the view of Borough officers”. Well, given last night, and seeing that you are all buddy buddy with one another, it’s really not surprising that you hold the same “views”. However, if you cannot provide justification for why you take the position of the Borough officers, one might be led to believe that something other than rationale, facts, and expertise is guiding your decision making.
I’m no Sherlock, but something sure smells fishy. To bad you guys decided to eat where you shit…now I have all the fuel I need to call in the dogs.
~Robyn Waite (March. 16, 2017)
Sadly, the application our community has been vigorously fighting was approved by the Greenwich Council planning board in January. For the sake of transparency, and anyone interested in the proceedings, feel free to have a listen to this audio file of the meeting. It’s quite enlightening….and the 20+ members of the community that spoke were ever impressive.
Despite the planning board approving the application from Berkeley Homes, nevertheless we are persisting! We have taken our concerns of multiple breaches of local and national policy up to the Mayor of London’s Office, and continue to attract media attention. Just today Mandy Little of the London News Online published this article on the issue, and last week Joe Dempsey compiled quotes for this article in News Shopper.
In response to these articles, I wanted to draw attention to the fact that the community is not opposed to plans to restore building 11 (or re-develop Woolwich in general). We all recognise the plan will “retain and restore” the building and are looking forward to using the space once again. However, building 10 is a completely different story. It is currently in use and not “at risk”. The introduction of an 11 story tower block on top of this beautiful heritage asset is completely unnecessary and damaging to the grade II listed building, the conservation area, and existing residents.
Note that the only justification Berkeley Homes gives for building this tower block is to offset the meagre £1.8m loss attributed to restoring building 11 – a building that they acquired knowing it would be in need of restoration. Surely there are alternative ways Berkeley could offset the cost….perhaps through anticipated profits from the many new builds in progress and planned within the same royal arsenal development??? Or how about instead of compensating the Council £1m in order to get out of providing affordable housing in the tower block, you keep the change and source £0.8m via the introduction of commercial units within the existing structure of building 10??? The viability assessment presented for justifying building this tower block and including zero affordable units out of the 146 proposed is very weak, and makes one think perhaps the only benefit of the proposed tower block is Berkeley Homes anticipated return of £6.8m.
I would also like to note that given this development is taking place within a conservation area, and is in relation to 2 listed buildings, according to policy and case law, decision makers must pay “special attention” and have a “strong presumption” against granting permission that would harm the character or appearance of the area. Given this planning application was approved on the basis of a weak financial case, said policy and case law were not appropriately applied in the making of the decision to approve this planning application. Also worth noting here, the experts on this – the Greenwich Conservation Group – registered their objection to the proposed tower block at the Nov. 22, 2017 planning board meeting.
Let’s turn our attention to how this tower block will impact existing residents. The main issue here is impact on daylight and privacy. The proposed building is just over 14m away from the existing East Carriage House (national recommendations for good practice is no closer than 18m). Berkeley Homes’ own report (questionably methodologically invalid) indicates 77% of units facing the proposed tower will be below the recommended national criteria for access to daylight. Those living in Bentham House (a retirement building) will also be negatively impacted with reductions to access to daylight. Note that these two existing buildings on either side of the proposed tower block are both predominantly social housing. That means that despite policy indicating that attention should be paid to protecting vulnerable populations, this planning application most negatively impacts vulnerable populations.
I feel like I could go on and on. There have been so many issues in this planning application raised by the community that they are hard to keep track of (and I would bore you to death if I kept going). Either way, the point is that these are real concerns grounded in policy that should be taken seriously.
As a community, we have impressively mobilised around this issue. Over 100 residents submitted letters of objection to the Greenwich Council. Those that did not engage throughout this process, or mocked us for doing so, felt like it was a waste of time and effort. Frankly, such a sentiment being so deeply ingrained in some pockets of this community speaks volumes to how people perceive Berkeley Homes’ relationship with the Greenwich Council.
We are not opposed to development, but we are opposed to inappropriate development that prioritises corporate interests over communities, and which fails to meaningfully engage with the people affected.
Robyn Waite – February 14th, 2017
Matt and I bought a property last year in Woolwich. We love our new home …however, the area is being rapidly, inappropriately, and distastefully developed by Berkeley Homes (a massive property developer in the UK). I have been really disappointed in how planning applications for the area have been dealt with, by both the developer and the local council. Feelings of injustice moved Matt and I to mobilise the community around our common concerns. We set up a Facebook group and have been coordinating community engagement with local plans since May. Despite the frustrations and lack of power I felt throughout this process, I have been really motivated and proud of my community for coming out in such large numbers to have our voices heard. Over 100 residents submitted letters of objections to the planning application (you can see ours below – fascinating read I assure you), and more than 20 of us spoke at the recent planning board meeting. We even managed to get some media coverage ahead of the meeting (see youtube clip above).
The board meeting last Tuesday resulted in a bit of a win for us. Board members decided to hold off on approving the application until they had more information – particularly around alternative service delivery routes. I am glad this happened, as it was very clear that the planning officers on the case working for the council were not well informed on the issues. They failed to offer answers to many of the board members questions and concerns… and in some cases, even provided inaccurate information. This is very concerning considering the planning officers had mad a recommendation for the board to accept the planning application ahead of the meeting.
Despite this little win there is still loads of work to be done. The board members seemed to be interested in mainly safety issues around the service delivery route proposed (fair, definitely an important issue), however, the communities concerns of breach of national and local policy concerning listed buildings, conservation areas, privacy, overlooking, amenity, open spaces for community use, etc. were largely ignored. So now what?? To be honest I don’t know. I’m slightly exhausted and feel defeated. I don’t know if it is possible to stick it to the man. The power imbalance between communities and corporates…heck even communities and governments these days…is massive. I feel like giving up – but I don’t think I can. If I do, I am accepting that the current power imbalance is inevitable, unchangeable, and ok. But it isn’t. And for that reason I feel this is only the start of my journey towards a life of uphill battles and perseverance. I can only hope that I continue to meet amazing people to join me along the way. There is power in numbers after all.
~ Robyn (Nov. 29, 2016)
COPY OF OUR LETTER OF OBJECTION IN RELATION TO THIS PLANNING APPLICATION
We are writing in reference to planning application 16/2807/F. Please note that we object to this planning application.
This is our second letter of objection in relation to this application. Despite amends made by the applicant, all our original objections (Submitted September, 22, 2016) remain pertinent.
Might I also express our disappointment with the process of community “consultation” throughout this planning application. Firstly, I have just viewed the Planning Board Summary document in relation to this application and noticed two rounds of consultation and respondent rates quoted. Upon receiving a subsequent notice associated with this application in October, many members of our community approached the council to seek information as to why a second notice was delivered, and whether or not they needed to resubmit their initial comments in order for them to be considered. The council advised that interested community parties did not need to resubmit comments. While indeed this was technically true, it is now clear that having resubmitted and / or elaborated on our comments would have been beneficial to strengthening our community response. The council failed to disclose this information and the community was not made aware that the notification of the planning application delivered in October was for the purpose of conducting a second round of “consultation” post minimal amendments made by the applicant. In addition to this, the summary document reveals that the council has made a recommendation that the planning board accept this planning application, which means this recommendation was made ahead of the close of the community consultation period. This demonstrates a disregard for considering community responses in the making of your recommendation.
I would also like to lodge my grievance with the council regarding the release of formal invitations to the planning board meeting. The community only received invitations exactly one week ahead of the meeting. Furthermore, given that the closing date for submitting comments associated with the October notification is November 16th, community members that commented on the notification received in October would not have been invited to the planning board meeting. This overtly excludes interested members of the community from attending the board meeting, where they are supposed to have the opportunity to address the board.
The overall process for community “consultation” is inaccessible and lacks transparency. Each planning notification that gets slipped through our door is illegible (half of the front page is covered in numbers and application references that have little meaning), and lacks a clear message as to what the letter and associated planning application is concerning. Further to this, members of the community are unable to discern the scale of the various planning applications they receive. The council frequently sends the same looking notification for a diversity of issues, which not only overwhelms, but confuses residents as to what is important and affects them, and what is merely a change of use to an existing space. Despite these challenges, if a member of the community proceeds to make an objection, numerous hurdles around accessing documents associated with the application, contacting the council, and understanding the process of review emerge. It is clear (or at least widely perceived by the community) that the council goes out of it’s way to make it difficult for community members to engage with planning applications.
ORIGINAL OBJECTIONS STILL RELEVANT:
In particular, we object to the negative impact to the conservation area, historic buildings and surrounding area, and local residents and community from the cumulative designs of the proposed taxi interchange, service-delivery route, extension to building 11, and residential development on top of building 10.
In their Planning Statement and supporting materials, the Applicant has failed to include all relevant information required for the Council to make an adequately informed decision. We bring additional information and relevant policy to your attention.
With regards to the proposed Taxi interchange, Berkley Homes states: “Within Royal Carriage Square and integrated into the landscaping proposal, a taxi turning point is proposed. This would support the operation of the adjacent Woolwich Crossrail Station, maximizing the Site’s accessibility and facilitating easier connections to elsewhere within the Borough.” (5.46); and “It is understood that previous studies relating to the Crossrail development and through liaison with TfL and Crossrail determined that there was a requirement for a formal taxi rank within sight of the station entrance and which had sufficient capacity to accommodate up to 50 taxis during the peak hour. It is estimated that this equates to a taxi rank with capacity for up to eight waiting taxis. On this basis a facility satisfying this demand and accommodating eight taxis has been provided within Royal Carriage Square.” (5.47)
We challenge these claims. The Applicant provides no evidence that a taxi interchange in the proposed location is a requirement of the Crossrail. On the contrary, ‘TfL Station public realm design guidance’ dated August 2015 (‘Station Guidance’), doesn’t require a taxi interchange to be within “site of the station entrance”, as the Applicant asserts, but states that “walking distance should be minimal” for taxi and private hire vehicles. In terms of further clarity for acceptable distances, the Station Guidance provides, “while interchange distance should generally be kept under 100 meters, designers should consider transport destinations that are within 200 meters (about a three-minute walk of the main station).” Further to this, Section 3.2 of the Station Guidance states, “we should consider the access points of other transport near the station and look to make the most of these connections for passengers using the interchange area.”
The Applicants proposed location for a taxi interchange does not follow Tfl guidance. Instead of considering access points to other transport near the station and using existing transport destinations, the planning application under review segregates the Crossrail station from the wider Woolwich community and proposes to introduce traffic to what is currently a pedal area. If efforts were being made to keep the Crossrail station accessible to the wider Woolwich community, the use of existing transportation destinations along Plumstead Road, which connects bus routes and the DLR with the Crossrail station, would be considered.
In addition to this, the Royal Arsenal Development itself offers a solution that would preserve the attractiveness of the proposed public square associated with this application. A planning application that introduces vehicle traffic beside an “attractive” public square is contradictory. There is ample space within 200m away, for example on Arsenal Way, along Plumstead Road or within Woolwich Town Centre that could accommodate up to 8 Taxis, and which utilizes existing roads and traffic routes.
Interestingly, in reference to “the initial 2013 public realm scheme proposed taxi drop off and interchange at Major Draper Street”, Berkeley Homes refuted the introduction of a taxi interchange to the space on the following grounds, which still hold true:
“3.19 During this time it was understood that the 2018 opening of the Crossrail Station, allied with the massive increase in pedestrian numbers and the requirements to change to other modes of transport (including taxis, private pick up and drop off, and cycles in a Zone 4 station such as Woolwich) would put immense pressure on an already pressurised space to the north east of Dial Arch Square besides Building 11 at the head of Major Draper Street. In addition it was noted that there would be:
– Conflict with significant pedestrian flows and service/delivery vehicles;
– Insufficient road width to provide taxi rank with adequate capacity;
– Insufficient space for taxis to turnaround without making three-point turns;
– Long and convoluted route for taxis to and from Plumstead Road; and
– A poor relation with residential uses along Major Draper Street and incompatible with aspiration to pedestrianise the Street.”
With regard to the proposed public square associated with this application, similar concerns emerge. Within the Royal Greenwhich Local Plan: Core Strategy with Detailed Policies, open space is emphasized as integral to cohesive and healthy communities. Given the high population density within the development, the community is currently in dire need of more open and green public spaces. This is particularly important in order to reduce the increasing stress on the existing open space in front of Dial Arch.
However, within the application under consideration, the prospects for creating an enjoyable and attractive open space for community use are slim. First of all, it would be better to describe what Berkeley Homes proposes as a “public square” as a “concrete rectangle with a few trees”, as introduction of a taxi interchange, the extension to building 11, and service delivery route, leaves little space for a public square, whilst introducing risks associated with the introduction of vehicles. Designs and mock-ups throughout Berkeley Homes planning application lack accuracy and scale, and do not reflect this reality. Furthermore, combined, all developments within the planning application close off space rather than open up space. Little physical space for a public square, coupled with the introduction of an 11 story development on top of building 10, creates a feeling of enclosure from the ground. Both physical and air space are relevant for creating “open spaces”, yet both are compromised in the planning application.
In addition to a lack of square footage available and creating a feeling of enclosure within the proposed “public square”, the proposed taxi interchange associated with this application negatively impacts the conservation and community enjoyment of the “public square”. More specifically, the proposal to introduce traffic into the area negatively impacts the community in the following ways:
It must be noted that buildings 10 and 11 under consideration in this application are Grade II listed heritage assets located within a conservation area. Paragraph 127 of the National Planning Policy Framework (‘NPPF’) provides, “when considering the designation of conservation areas, local planning authorities should ensure that an area justifies such status because of its special architectural or historic interest, and that the concept of conservation is not devalued through the designation of areas that lack special interest.” Paragraph 132 of the NPPF provides that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.” And paragraph 137 of the MPPF – provides that “Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance.”
The planning application and proposals for both building 10 and 11 significantly compromise the integrity of, and detract from, these heritage assets – which is particularly damaging as there are opportunities to enhance and better reveal their significance. In the proposed extension and structural alteration to building 11, merely the façade of the heritage building will be retained on one side of the building, while an 11 story development on top of building 10 would greatly detract from it’s significance within the space. Overall, the development proposals for building 11 and 10 are not in keeping with the character of their heritage or the distinctiveness of the wider Royal Arsenal development.
The justifications that Berkeley Homes has provided for significantly altering these heritage assets is cost and time. They make reference to a viability assessment (that has not been made public and brings the transparency associated with this planning application into question) claiming that this over development of the area is necessary in order to finance the “saving” of building 11. This corporate enterprise is not hard done by when their 2016 profits were £479.9 million after tax. Their viability assessment should not be taken seriously and does not justify a lack of respect for the people, environment, and heritage assets that reside in this conservation area. In reference to time, Berkeley Homes pressures the council to make a decision quickly by stating that development must be completed before the Crossrail station is open. We see this as a method of bullying and manipulative use of strategically timing their planning application to leverage their position for maximizing profits within the development.
In addition to this planning application affecting two Grade II listed buildings and a registered conservation area, also note that this planning application is for an area where particularly vulnerable populations within the Royal Arsenal development reside. I do hope the council carefully considers the planning application under review.
To conclude, we request that the current planning application is rejected and encourage the Application to consider a redesign that reflects the collective concerns of the community.
Please keep us informed as to when this will be taken to the planning committee for consideration. We request an opportunity to speak at the planning authority committee at which the application is decided.
Robyn & Matt